Tony Spicer
Well Known Member
Two years ago when I was starting my RV-3, I wondered if it would be possible for it to be LSA compliant. So I asked EAA. Their response from November 2005 follows:
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"Since you are the builder of the aircraft you determine the gross weight, etc. and if operating as a sport pilot, you are responsible for flying only aircraft which qualify as an LSA.
The FAA preamble states:
"The FAA notes that compliance with light-sport aircraft parameters can be more readily verified for type-certificated aircraft than for amateur-built aircraft certificated under existing ?21.191 (g). Amateur-built aircraft do not have a TC, a flight manual, or a type certificate data sheet. Because of this, it may be difficult to determine if aircraft with other than a standard airworthiness certificate meet the limits listed for a light-sport aircraft and can be operated by a sport pilot. The FAA anticipates that the aircraft design consensus standard will include methodologies that will readily enable a determination that an aircraft design meets the light-sport aircraft definition."
The ASTM standards have addressed the FAA's preamble language. The ASTM standards clearly define what V sub H is in 3.2.32. The Committee felt and the FAA agreed that there was nothing more to say, fly the aircraft with maximum continues power in level flight record the speed and correct for standard day the answer is the answer nothing more needs to be defined.
The ASTM standard also includes 4.3.1 which states:
Maximum RPM shall not be exceeded with full throttle during takeoff, climb, or flight at 0.9 V H, and 110 % maximum continuous RPM shall not be exceeded during a glide at V NE with throttle closed.
So the above is one way to prove that your aircraft is an LSA which is acceptable to the FAA. Can you establish Vh some other way? I would say yes for an amateur built but I would definitely document it as part of my flight testing program.
Practical considerations are that the burden of proof will be on you to establish that an RV-3 meets the definition. A knowledgeable FAA Inspector who "knows" that an RV-3 doesn't fit LSA will violate you first and then let you prove that it is in compliance. If the FAA has nothing else to go on, they will no doubt revert to the engine manufacturer's documentation, which will have a specific maximum continuous power rating (which definitely won't be 55% power!). For example, Lycoming calls out a maximum continuous rated power and RPM for the O-320-A2B of 150 hp and 2700 rpm. It would be pretty tough to convince an FAA inspector that the Lycoming engine in your homebuilt (even if it's modified in some way) has a substantially different maximum continuous power rating than what's on the TC. Van's probably will give you no support since they do not view it as LSA eligible.
Also, I would guess that you could also run into some insurance problems as they will use readily available reference material to determine what they will insure for sport pilot operations."
Tony Spicer (just the messenger)
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"Since you are the builder of the aircraft you determine the gross weight, etc. and if operating as a sport pilot, you are responsible for flying only aircraft which qualify as an LSA.
The FAA preamble states:
"The FAA notes that compliance with light-sport aircraft parameters can be more readily verified for type-certificated aircraft than for amateur-built aircraft certificated under existing ?21.191 (g). Amateur-built aircraft do not have a TC, a flight manual, or a type certificate data sheet. Because of this, it may be difficult to determine if aircraft with other than a standard airworthiness certificate meet the limits listed for a light-sport aircraft and can be operated by a sport pilot. The FAA anticipates that the aircraft design consensus standard will include methodologies that will readily enable a determination that an aircraft design meets the light-sport aircraft definition."
The ASTM standards have addressed the FAA's preamble language. The ASTM standards clearly define what V sub H is in 3.2.32. The Committee felt and the FAA agreed that there was nothing more to say, fly the aircraft with maximum continues power in level flight record the speed and correct for standard day the answer is the answer nothing more needs to be defined.
The ASTM standard also includes 4.3.1 which states:
Maximum RPM shall not be exceeded with full throttle during takeoff, climb, or flight at 0.9 V H, and 110 % maximum continuous RPM shall not be exceeded during a glide at V NE with throttle closed.
So the above is one way to prove that your aircraft is an LSA which is acceptable to the FAA. Can you establish Vh some other way? I would say yes for an amateur built but I would definitely document it as part of my flight testing program.
Practical considerations are that the burden of proof will be on you to establish that an RV-3 meets the definition. A knowledgeable FAA Inspector who "knows" that an RV-3 doesn't fit LSA will violate you first and then let you prove that it is in compliance. If the FAA has nothing else to go on, they will no doubt revert to the engine manufacturer's documentation, which will have a specific maximum continuous power rating (which definitely won't be 55% power!). For example, Lycoming calls out a maximum continuous rated power and RPM for the O-320-A2B of 150 hp and 2700 rpm. It would be pretty tough to convince an FAA inspector that the Lycoming engine in your homebuilt (even if it's modified in some way) has a substantially different maximum continuous power rating than what's on the TC. Van's probably will give you no support since they do not view it as LSA eligible.
Also, I would guess that you could also run into some insurance problems as they will use readily available reference material to determine what they will insure for sport pilot operations."
Tony Spicer (just the messenger)